First Corporate Tax cycle
Related-party activity has not yet been mapped under the UAE definitions or reconciled to the tax-return process.
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UAE Transfer Pricing / Impact Assessment
Know where Transfer Pricing applies.Then decide what to prepare.
A focused first-stage review of the relationships, transactions and evidence behind your UAE Corporate Tax position. The assessment separates the arm's-length requirement from disclosure and formal-documentation obligations, then turns the findings into a workable action plan.
Domestic + cross-borderBoth transaction populations are considered
Relationship-firstRelated Parties and Connected Persons mapped
Prioritised actionsImmediate, filing and ongoing work separated
When this service fits
Choose it for a defined business need.
Use the assessment when the business needs a defensible view of what is in scope before commissioning a policy, benchmark or formal file.
New intercompany arrangement
A management charge, loan, licence, distribution model or cost allocation is being introduced or materially changed.
Unclear compliance level
The group is unsure which disclosures, supporting records, Local File or Master File obligations apply.
Structural change
Ownership, functions, financing, Free Zone status or the location of key activities has changed during the period.
How the engagement moves
Four stages. A defined output at every stage.
The work moves from legal and commercial relationships to the amounts recorded in the accounts. Each conclusion is tied to an identified transaction and evidence requirement.
01Stage 01
Map the relationships
Identify Related Parties and Connected Persons using ownership, control, management and family-relationship information—not only the financial-statement note.
Stage outputConfirmed relationship list
02Stage 02
Build the transaction inventory
Group the sale of goods, services, financing, intangibles, assets, liabilities and other arrangements by party, direction and value.
Stage outputControlled-transaction register
03Stage 03
Test the obligations
Assess the arm's-length support, return-schedule population and formal documentation requirements that follow from the facts.
Stage outputCompliance obligation matrix
04Stage 04
Prioritise the response
Separate corrections needed before filing from policy, benchmarking, documentation and continuing-control actions.
Stage outputPrioritised action plan
Defined deliverables
What management receives.
The assessment is designed to be used by finance and management after the engagement—not left as a general tax memo.
Relationship map
A structured list of Related Parties and Connected Persons, with the relationship basis and open points clearly recorded.
Controlled-transaction register
A category-level register of counterparties, transaction flows, values, agreements, invoicing and available support.
Compliance matrix
A clear distinction between arm's-length support, return disclosures, Local File, Master File and other identified requirements.
Prioritised action memo
Actions ranked by filing dependency, evidence gap and practical exposure, with owners and required source records.
Current UAE framework
The arm's-length rule is wider than the formal-documentation thresholds.
Transactions with Related Parties and Connected Persons can require arm's-length support even when a disclosure schedule, Local File or Master File is not triggered. The assessment therefore starts with the transaction population rather than a threshold in isolation.
Federal Tax Authority — Transfer Pricing Guide (CTGTP1)Domestic and foreign arrangements
The counterparty can be in the UAE mainland, a Free Zone or another jurisdiction.
More than goods and services
Loans, guarantees, intangibles, assets, liabilities and other arrangements can also be controlled transactions.
Terms and actual conduct
Agreements, functions, risks, benefits, invoices and recorded results should tell the same commercial story.
Contemporaneous support
Material positions are easier to support when reviewed during the period and before the Corporate Tax return is filed.
Records to begin
Start with the evidence that creates the position.
We tailor the request list after an initial call. The following records normally provide the starting population.
- Legal and management organisation charts
- Ownership, control and family-relationship information
- Trial balance, general ledger and related-party ledgers
- Intercompany agreements, invoices and credit notes
- Loan, guarantee and cash-pooling records
- Financial statements and Corporate Tax filing status
- Group revenue and consolidated accounts where relevant
- Descriptions of functions, decision-making and risk control
Questions before you engage
Clear answers about this scope.
These answers explain the service boundary. The final treatment and engagement plan depend on the entity, period, records and current UAE requirements.
Is this only relevant to multinational groups?
No. UAE domestic transactions can also fall within the Transfer Pricing rules. The size and structure of the group affect formal obligations, but not whether a controlled transaction should be considered.
Can we use the related-party note in our financial statements?
It is useful evidence, but it may not identify the complete population under the UAE Corporate Tax definitions. We reconcile it to ownership, management and ledger data.
Will the assessment tell us whether a Local File is required?
Yes. We assess the relevant conditions using the information provided and show the conclusion in the compliance matrix.
Does the service correct our pricing?
It identifies gaps and required actions. Policy design, benchmarking, accounting adjustments or documentation can then be scoped for the transactions that need them.
Should this be done before the Corporate Tax return?
Preferably. An early review leaves time to reconcile values, obtain missing evidence and address pricing outcomes before the return is finalised.
Related services
Move to the service that matches the next requirement.
Each page has its own defined purpose. Use the current service for the work described here, or choose another service when the business need changes.
Contact Us
Request a TP Impact Assessment Start with the transaction map, not a document bundle.
Tell us which group entities, owners or connected people transact with the UAE business so the first conversation starts with the right scope.